If that seems odd, keep in mind that most of Apple’s cash is held overseas, and to bring it home would incur a financial penalty equal to the full United States federal corporate tax rate: 35%. So, the company is looking to raise another $17 billion in debt to pay its shareholders a part of its profits.

Given low current interest rates on corporate paper, it is an order of magnitude cheaper for Apple to borrow billions at home than to bring billions home. And with the Fed prioritizing growth instead of fear of inflation, that’s not likely to change.

I’ve reached out to Apple for comment on the reported debt sale.

ZeroHedge published a graph today detailing why Apple needs to raise more local capital to execute its increased shareholder return program:

So, while Apple remains massively solvent, its lack of capital in its home market makes it mildly difficult for it to return cash to shareholders at the rate that they demand.

Icahn aside, it’s fun to note the implied penalty that the United States government is enacting onto Apple, or, that Apple is willing to pay to avoid what some would call fair taxation — sure, it will pay a few points on the debt, but that cost represents a massive savings.